https://www.taxtmi.com/caselaws?id=412029 Reopening of assessment under Section 147 was upheld because the reassessment was founded on tangible material that had not been examined in the original assessment, including a mismatch between Form 26AS receipts and the profit and loss account, as well as material from the Justice M.B. Shah Commission report. The Court held that this was not a mere change of opinion, since no prior opinion had been formed on the issue now reopened, and that the discrepancy gave reason to believe income had escaped assessment. It also found that the assessee had not made full and true disclosure of material facts, so the challenge to the reassessment notices and rejection of objections failed. en-us Wed, 01 Sep 2021 00:00:00 +0530 Tue, 07 Sep 2021 09:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=412029 Reopening of assessment under Section 147 was upheld because the reassessment was founded on tangible material that had not been examined in the original assessment, including a mismatch between Form 26AS receipts and the profit and loss account, as well as material from the Justice M.B. Shah Commission report. The Court held that this was not a mere change of opinion, since no prior opinion had been formed on the issue now reopened, and that the discrepancy gave reason to believe income had escaped assessment. It also found that the assessee had not made full and true disclosure of material facts, so the challenge to the reassessment notices and rejection of objections failed. Case-Laws Income Tax Wed, 01 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=412029